Linpac Plastics, Inc. - Executive Summary
I. EXECUTIVE SUMMARY |
This Executive Summary comprises the Rule 40 CFR 68.155 of
the Clean Air Act as it applies to Linpac Plastics. The Tasks,
1-4 indicate Environmental Engineering Consultants, Inc.'s
evaluation of Linpac Plastics' compliance with the stated Rule.
40 CFR Part 68.155(a):
Accidental release prevention and emergency response policies;
Linpac's Process Safety Management (PSM) Policy requires
daily inspections by maintenance mechanics and the Plant
Engineer. Butane gas detectors are located in the Butane
Storage Tank Area and in the Butane Pump Room. These detectors
are connected to a butane detection warning panel with lights and
a warning horn, it is also integrated into the fire alarm system.
Butane pumps and motors are regularly rotated with their backups
to verify proper working order and to allow for scheduled
maintenance. The Accidental Release Prevention Plan (ARP) is to
call 911 for emergency response, sound the evacuation ala
evacuate the building. If possible, the butane emergency
shut-off will be activated and the power turned off to the butane
motors. Operators will turn their equipment off as they
evacuate. Maintenance supervisors and lead operators will
provide first aid until paramedics arrive.
TASK 1 was to perform a Process Safety Management and
Accidental Release Plan (PSM/ARM) Compliance Audit. This
compliance audit indicated good overall compliance and
excellent results, with no accidents related to the Butane
System. We recommend that all procedures be updated with the same
format as the "Hazard Communication Plan", and that a
"Date of Next Revision Due_____" statement be added to clarify
the age of the procedure.
40 CFR Part 68.155(b):
Stationary source and regulated substances handled;
Linpac Plastics, Inc. is a manufacturer of polystyrene
plastic. Linpac sells the polystyrene to clients and also uses
it to manufacture various plastic containers, such
cartons and "carry out" food containers. Butane is used as a
blowing agent in the manufacturing process. Butane is stored on
site in an 18,000 gallon tank under pressure. Butane is the only
"regulated substance" handled by Linpac Plastics.
40 CFR Part 68.155(c):
Worst case release scenario(s) and the alternative release
TASK 2 was to perform a review of the hazard assessment
elements. An off-site consequence analysis was required to
evaluate specific potential release scenarios, with a worst-case
scenario and an alternative case for computer modeling.
* The worst case release scenario indicated a vapor cloud
explosion would have an effect to a distance of 0.2
miles (1000 feet). Our research indicates that three (3)
I. EXECUTIVE SUMMARY continued:
vacant buildings, four (4) active businesses, and two
(2) Sebring Airport Authority maintenance buildings, and the
water plant could potentially be affected i
n this scenario
(Figure 1, Map of 1,000 feet radius).
* The Alternative Release Scenario indicated that a vapor
cloud fire would have an effect to 0.1 miles (500 feet).
The vapor cloud fire scenario could affect one (1)
active business, three (3) vacant buildings and the
Sebring Airport Authority water plant (Figure 2, Map of 500
feet radius). The residential population and the
environmental receptors are not affected by either
Linpac's Administrative Controls and Mitigation Measures
include the following:
* The butane gas detection sensors, with monitoring
system and associated alarm.
* A locked gate and the chain link fence enclosing the
tank and the unloading station.
* Back up pumps and motors.
* Explosion-proof equipment.
* Gravel has been placed around the tank and the
unloading station to dissipate a spill.
* Only trained mechanics are allowed to perform
ance on the butane system.
* Safety procedures are reviewed during Safety Meetings.
40 CFR Part 68.155(d):
General accidental release prevention program and
chemical-specific prevention steps;
The general Accidental Release Prevention Program and
Chemical-Specific Prevention Steps are as follows:
* Only trained maintenance mechanics are allowed to perform
maintenance on the butane system.
* All work is reviewed by a supervisor and the Plant Engineer
before it is performed to ensure compliance with safety
rules and to prevent an accidental release.
* In general, all maintenance work related to the butane
system is performed using a two-person team to ensure safety
compliance and to prevent an accidental release.
* A butane trained employee is always present during the
unloading process to ensure safety compliance and to prevent
an accidental release.
* The program complies with safety precautions, monitoring,
record keeping, reporting, operator training, vapor
recovery, secondary containment, work practices, standard
operating procedures modifications as needed, the generation
of a "Hot Work Permit", and the OSHA PSM Rule.
I. EXECUTIVE SUMMARY continued:
TASK 3 was to develop a Detailed Accidental Release
Prevention Program. Our review indicated that four areas needed
to be addressed to be in full compliance with the regulations.
1. Initiate safety compliance audits.
2. Implement an incident investigation procedure, and
3. Implement an Employee Participation Plan.
4. Perform a design review of compliance with the National
Fire Protection Association Codes relevant to the
40 CFR Part 68.155(e)
Five-year accident history;
Linpac safety records indicate that there have been no
accidents related to the butane system during the last five (5)
40 CFR P
Emergency response program;
TASK 4 was to develop an Emergency Response Program. We
have chosen to use the 911 emergency phone system as our
Emergency Response Program (ERP). The Sebring Regional Airport
Volunteer Fire Department is less than one mile away and has been
notified of the existence of the butane tank, in compliance with
the State Emergency Response Program. The fire department has
agreements with fire departments in three surrounding cities
(DeSoto City, Lorita and the City of Sebring) to provide
assistance when needed. Linpac's ERP identifies only the actions
to take until the Fire/Rescue Personnel arrive.
40 CFR Part 68.155(g)
Planned changes to improve safety
To improve safety at the facility, the following procedures
will be implemented:
* A portable butane detection monitor will be purchased
* Evacuation drills will be practiced.
* Safety Compliance Audits will be initiat
* An Incident Investigation Procedure will be instituted.
* Implement an Employee Participation Plan.
* Linpac will perform a Design Review of Compliance with
the National Fire Protection Association Codes relevant
to the butane system.